Comments
Max, I don't think presence at any level is enough to qualify as a REC. What if we measure to the microgram per meter cubes levels? Los Angeles air has detectable levels of PCE if we measure to the micro gram per meter cubes levels. Is this presence? Yes, but background air would clearly not be a REC, as background PCE is a miminis condition.Mike, I love this blog. It good to understand where you can from and how it shapes your approach to problems. Clients are well served to have an environmental engineer such as yourself on their problems.
Larry,
I agree that a smaller list of environmental consultants ultimately produces higher quality Phase 1 Environmental Site Assessments. Lenders always struggle to get consistent reports from a large number of consultants.
Air in Los Angeles is above California Human Health Screening Levels (CHHSLs) for PCE. It does not suprise me that benzene is above CHSSLs is high in Carson. People back east might wonder why we live here--the weather is quite good.
Nevertheless, you have to wonder if the California's standard for save air CHHSLs are a bit too conservative.
Larry, this blog is very interesting. I wonder how much it cost to mitigate the vapor encroachment risk associated with the environmental contamination. No doubt that mitigation of vapor intrusion during development can prevent future Phase 1 Environmental Site Assessments from recommending Phase 2 Environmental Testing!
I recently did a Phase 1 Environmental Site Assessment on a site with a vapor barrier accross the whole site. I wanted to recommend drilling to characterize the extent of the contamination, but any drilling would have puncture the vapor barrier.
The City of Los Angeles has a been requiring methane testing in methane zones for the past 10 years. Building permit applicants determined to be within a methane zone or a methane buffer zone are required to preform methane soil gas testing.
The primary concern is explosion risk and most of the designated methane zones are former oil fields.
A Historical Enviromental Condition is a very useful characterizetion of an issue in a Phase 1 Environmental Site Assessment, as it allows us to alert the user of the environmental contamination and potential environmental liability without requiring Phase II Environmental Testing.
I think we all agree that a Vapor Encroachment Condition (VEC) is a Recognized Environmental Condition (REC). If my client wants binary advise, then I am done: VEC = REC.
Some clients want us to go a bit further at the end of a Phase I Environmental Site Assessment to support of the business decision at hand. I wonder if we can also agree that the Expected Environmental Loss associated with an off-site REC / VEC is generally substantially lower than the Expected Environmental Loss associated with an on-site Recognized Environmental Condition.
Larry, thank you for your post. As more and more states create vapor intrusion centric regulations, Phase I Environmental Site Assessments give greater attention to vapor intrusion issues.
I agree that a lot of lenders are not sure if they are getting a Level 0 or Level 1. My firm does far more Level 1 PMLs, but we Level 0 upon request. I would join the Seismic Guy in encouraging lenders to be clear about what they want when they ask their engineering vendor for a bid!